American Occupational Therapy Association - AOTA



Via online submission to [Date]Department of Health and Human ServicesCenters for Medicare & Medicaid ServicesAttention: CMS – 1744 – IFCP.O. Box 8016Baltimore, MD 21244-8016Re: Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to theCOVID-19 Public Health EmergencyDear Administrator Verma:I appreciate the opportunity to comment on this interim final rule published at 85 Federal Register 19230 on April 6, 2020.[Introduce yourself and explain how you use telehealth to successfully reach functional outcomes.]I strongly urge HHS and CMS to take immediate steps to ensure patient safety and protect health care providers now by using the authority granted under Social Security Act 1135(b)(8), as amended by the CARES Act, to expand the types of providers eligible to furnish telehealth services under Medicare to include audiologists, occupational therapy practitioners, physical therapy practitioners, and speech-language pathologists during the COVID-19 public health emergency.Section 3703 of the Coronavirus, Aid, Relief, and Economic Security (CARES) Act amends section 1135 of the Social Security Act, to grant HHS the authority to waive the requirements of section 1834(m) of the Act. Specifically, 1135 grants the Department of Health and Human Services (HHS) waiver authority during National Emergencies. The CARES Act extended this waiver authority to include “the requirements of 1834(m), including limitations on practitioners eligible to provide and bill Medicare telehealth services.”The interim final rule lists the following occupational therapy services as being approved for telehealth, by CPT? code:971659716697167971689711097112971169753597750977559776097761I appreciate the first step CMS has taken in adding occupational therapy services to the telehealth services list through relevant Physical Medicine and Rehabilitation CPT codes. However, I believe the exclusion of 97530, 97129, and 97130 [any additional codes you feel could be used for telehealth] is an oversight.97530Therapeutic activities, direct (one-on-one) patient contact (use of dynamic activities to improve functional performance), each 15 minutes 97129 Therapeutic interventions that focus on cognitive function (e.g., attention, memory, reasoning, executive function, problem solving, and/or pragmatic functioning) and compensatory strategies to manage the performance of an activity (e.g., managing time or schedules, initiating, organizing, and sequencing tasks), direct (one-on-one) patient contact; initial 15 minutes97130Each additional 15 minutes (List separately in addition to code for primary procedure.)[Add other codes and descriptions]Occupational therapy practitioners help patients reach optimal functional performance through the use of activities that enhance skill sets. Therapeutic activities, identified under CPT code 97530, are universal, used by occupational therapy practitioners in all settings, for all conditions. [Give an example where you would perform 97530 using telehealth.] In addition, occupational therapy practitioners treat cognitive impairments because these impairments have the potential to compromise patient safety and long-term well-being, especially for frail and chronically ill elderly patients. Early identification of cognitive impairments that relate to performance of activities of daily living (ADLs), identified under CPT codes 97129 and 97130, allows for the timely implementation of an occupational therapy care plan. The plan can include implementing the supports, including training and modifications, necessary to prevent harmful events that commonly happen during routine everyday activities for patients with cognitive impairments; for example, falls due to problematic sequencing of activities during a bathing or dressing activity.[Give an example of where you would perform 97129, 97130 using telehealth.][Add additional codes with examples.]I would like to thank CMS for all of its efforts in moving forward with telehealth in these unprecedented times. Accordingly, I urge CMS to quickly broaden coverage for Medicare telehealth services under the CARES Act 1135(b)(8) waiver authority so that beneficiaries can receive medically necessary health care services from occupational therapy practitioners. Thank you again for your consideration.Sincerely, ................
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